10.10 - Record Retention and Access Policy

Record Retention

Financial records, supporting documents, statistical records, and all other records pertinent to a Federal award must be retained for a period of three years from:

1. The date of submission of the final expenditure report or,
2. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as reported to the Federal awarding agency or pass-through entity.

Records for real property or equipment. Records for real property and equipment acquired with Federal funds must be retained for 3 years after final disposition.

Records for program income transactions after the period of performance. In some cases, recipients must report program income after the period of performance. Where there is such a requirement, the retention period for the records pertaining to the earning of the program income starts from the end of the University fiscal year in which the program income is earned.

Indirect cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable.

1. If submitted for negotiation. If the proposal, plan, or other computation is required to be submitted to the Federal Government (or to the pass-through entity) to form the basis for negotiation of the rate, then the 3-year retention period for its supporting records starts from the date of such submission.
2. If not submitted for negotiation. If the proposal, plan, or other computation is not required to be submitted to the Federal Government (or to the pass-through entity) for negotiation purposes, then the 3-year retention period for the proposal, plan, or computation and its supporting records starts from the end of the fiscal year (or other accounting period) covered by the proposal, plan, or other computation.

Exceptions

The only exceptions are the following:

1. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.
2. When the University is notified in writing by the Federal awarding agency, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the retention period.
3. When records are transferred to or maintained by the Federal awarding agency or pass-through entity.

Single Audit Records

Although the Uniform Guidance only requires retention of audit documentation for a minimum period of three years, the auditing standards (AICPA, Professional Standards, AU-C sec. 230), extend the retention requirement to five years. Therefore, if a federal award is chosen for testing during a single audit performed under 2 CFR Part 200, Subpart F, those records will be kept for the required five years.

Access to Records